The inherent international tax regime and its constraints on Australia's sovereignty

On 1 November 2011 the Minister for Financial Services and Superannuation, the Honourable Bill Shorten MP, announced that Australia would be undertaking a reform of the ‘transfer pricing rules in the income tax law and Australia’s future tax treaties to bring them into line with international best practice, improving the integrity and efficiency of the tax system.’ Mr Shorten stated that the reason for the reform was that ‘recent court decisions suggest our existing transfer pricing rules may be interpreted in a way that is out-of-kilter with international norms.’ Further, he stated that ‘the Government has asked the Treasury to review how the transfer pricing rules can be improved, including but not limited to how to be more in line with international best practice.’ He urged all interested parties to participate in this consultation process. On 16 March 2012, an Exposure Draft and accompanying Explanatory Memorandum outlining the proposed amendments to implement the first stage of the transfer pricing reforms were released. Within the proposed changes is the explicit embedding of the use of the OECD’s Model Tax Convention on Income and on Capital and Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations to help determine the arm’s length price. Does this mean that Australia engages in an international tax regime?

Australia's adoption of an international tax regime : to engage or not to engage?

On 1 November 2011 the Minister for Financial Services and Superannuation, the Honourable Bill Shorten MP, announced that Australia would be undertaking a reform of the ‘transfer pricing rules in the income tax law and Australia's future tax treaties to bring them into line with international best practice, improving the integrity and efficiency of the tax system.’ Mr Shorten stated that the reason for the reform was that ‘recent court decisions suggest our existing transfer pricing rules may be interpreted in a way that is out-of-kilter with international norms.’ Further, he stated that ‘the Government has asked the Treasury to review how the transfer pricing rules can be improved, including but not limited to how to be more in line with international best practice.’ He urged all interested parties to participate in this consultation process.

Explaining internationalisation of small to medium sized enterprises within the Queensland food and beverage industry

The prevalence of International New Ventures (INVs) has increased during the past twenty years. Nevertheless, to date there has been no general consensus within the literature on an explanation as to the rapid internationalisation of some firms. Do they follow a similar process to other firms that internationalise based on a more ‘measured’ incremental sequential process of internationalisation. This paper proposes and tests an innovation diffusion model of the internationalisation of small firm INVs and others by drawing on key innovation diffusion models from the literature. The results of this analysis indicate that the synthesised model of export adoption is effective in explaining the internationalisation process of INVs and other firms within the Queensland Food and Beverage Industry. Significantly, the features of the original innovation diffusion models developed in the consumer behaviour literature, which had limited examination within the internationalisation literature, were confirmed. This includes the ability of firms, or specifically decision-makers, to skip stages based on previous experience.

Using cases in a mixed learning environment : meeting the challenges of higher education reform

This paper explains the context for pedagogy in a specific undergraduate course; the comparative benefits of using cases in a mixed learning environment (simultaneous large and small groups); and illustrates one significant way for universities to respond to increasing demand for delivery efficiency while maintaining high quality learning outcomes. Thus, to achieve objectives of the subject, tutorial classes expand on what is taught in lectures and provide the necessary context to analyse cases in more detail. A small, qualitative study explored experiences of market research tutors with the use of case method teaching reported. Implications of the study for case teaching in higher education are identified.

The role of alternative message strategies in advertising performance : challenges to the B2B marketing paradigm

In this study the impact of message strategy on advertising performance will be in examined in a business-to-business (B2B) context. From a theoretical standpoint, the study will explore differences in message type between symbolic and literal approaches in B2B advertisements. While there has been much discussion on the effect of symbolism, (eg. metaphors, abstract images and figurative language), an empirically-tested scale that measures the degree of symbolism has not been developed. This research project focuses on development of a methodological scale to accurately test the difference in the direction of message appeals. Thus, insights in the role of message strategy in the B2B adoption process are anticipated with contributions in future consumer and business advertising research.

FINALE of the U.N. International Year of Forests : culmination with a concert

Our Counselling and ISS team organised, in early December, 2011 a celebration of two years of art workshops and activities provided for our University post-graduate research students. The workshops had a number of benefits. They were to raise awareness of biodiversity and forests as well as providing a forum for engaging with others and an opportunity to belong to a semi-regular group. The 2010 theme had been the United Nations International Year of Biodiversity and the 2011 theme had been the United Nations International Year of Forests.

Management characteristics and the decision to internationalize : exploration of exporters vs. non-exporters within the Chilean wine industry

The objective of this study was to identify key factors differentiating between exporters and non-exporters in the Chilean wine industry. Based on survey data collected from 61 wineries, the findings show that the main barriers for non-exporters are the lack of financial resources, limited quantities of stock for market expansion, management’s lack of knowledge and experience, and the high cost of travelling and participating in trade shows. The results also show that managers have educational levels and international experience exceeding those of other comparable New World wineries. Finally, in developing their main international markets, Chilean wineries did not target psychically close markets as identified in previous wine industry studies

Kaleidoscopes and contradictions : the legitimacy of social media for public relations

If the current discourses of progress are to be believed, the new or social media promise a kaleidoscope of opportunity for connecting and informing citizens. This is by allegedly revitalizing the fading legitimacy and practice of institutions and providing an agent for social interaction. However, as social media adoption has increased, it has revealed a wealth of contradictions both of its own making and reproduction of past action. This has created a crisis for traditional media as well as for public relations. For example, social media such as WikiLeaks have bypassed official channels about government information. In other cases, social media such as Facebook and Twitter informed BBC coverage of the Rio Olympics. Although old media are unlikely to go away, social media have had an impact with several large familybased media companies collapsing or being reintegrated into the new paradigm. To use Walter Lippman’s analogy of the phantom public, the social media contradictorily serve to both disparate the phantom in part and reinforce it...

First international workshop on theory and applications of process visualization

The representation of business process models has been a continuing research topic for many years now. However, many process model representations have not developed beyond minimally interactive 2D icon-based representations of directed graphs and networks, with little or no annotation for information over- lays. With the rise of desktop computers and commodity mobile devices capable of supporting rich interactive 3D environments, we believe that much of the research performed in computer human interaction, virtual reality, games and interactive entertainment has much potential in areas of BPM; to engage, pro- vide insight, and to promote collaboration amongst analysts and stakeholders alike. This initial visualization workshop seeks to initiate the development of a high quality international forum to present and discuss research in this field. Via this workshop, we intend to create a community to unify and nurture the development of process visualization topics as a continuing research area.

Public realm and transport, international best practice case studies and opportunities for Brisbane

This report was prepared for Lat 27 Pty Ltd for the purpose of conducting a City Centre Public Realm and Active Transport Study for Urban Renewal Brisbane, Brisbane City Council. In this review, we highlight some key learnings and recommendations from innovative projects across the globe to inform public realm design and help facilitate active transport in subtropical Brisbane. Traditionally, Australian cities have been have been based on northern European models. This report is informed by the view that planners and urban designers must look beyond that paradigm to redefine and re-conceptualise our city in a different way, one that values our unique local identity and climate. In re-designing Brisbane’s public realm, therefore, design interventions and responses must celebrate our unique identity and outdoor lifestyle and address the subtropical climate's reality of life in warm humid summers and cool dry winters. The current period of rapid urban change, and the imperative to adapt to climate change, together offer an opportunity to prioritise and integrate design features that provide shade and shelter from sun and summer rain, open and permeable urban environments that facilitate cooling air movement, and connections to water and nature, so that the urban built form co-exists within an inviting, functional and memorable natural landscape. To inform this transformation, this review provides insight into international experiences and best practices. To date, although there is much practice-based knowledge, academic studies outlining learnings and recommendations from case studies (especially in a subtropical context) remain rare. Thus, a range of sources (industry reports, websites, journal articles and books) have been utilised.

Toward a shopping typology of primary male grocery shoppers

Purpose – The purpose of this paper is to segment primary male grocery shoppers based on store and product attribute evaluations. A rich profile for each segment is developed. These developed contemporary shopper typologies are contrasted against earlier works. Design/methodology/approach – Data of 280 male grocery shoppers was attained by a survey questionnaire. Factor analysis, cluster analysis and ANOVA were employed to develop specific segments of male shoppers. Findings – Four distinct cohorts of male shoppers emerge from the data of eight constructs, measured by 46 items. One new shopper type, not found in earlier typology literature, emerged from this research. This shopper presented as young, well educated, at the commencement of their career and family lifecycle, attracted by a strong value offer and willingness to share the family food shopping responsibilities. Practical implications – Research outcomes encourage supermarket retailers to implement targeted marketing and rationalized operational strategies that deliver on attributes of importance. Originality/value – This research makes a contribution to segmentation literature and grocery retail practice in several ways. It presents the first retail typology of male supermarket shoppers, employing a cluster analysis technique. The research provides insights into the modern family food shopping behaviour of men, a channel in which men are now recognised as equal contributors. The research provides the basis for further gender comparative and cross-contextual studies.

Phenomenology as a method for exploring management practice

Phenomenology is a term that has been described as a philosophy, a research paradigm, a methodology, and equated with qualitative research. In this paper first we clarify phenomenology by tracing its movement both as a philosophy and as a research method. Next we make a case for the use of phenomenology in empirical investigations of management phenomena. The paper discusses a selection of central concepts pertaining to phenomenology as a scientific research method, which include description, phenomenological reduction and free imaginative variation. In particular, the paper elucidates the efficacy of Giorgi’s descriptive phenomenological research praxis as a qualitative research method and how its utility can be applied in creating a deeper and richer understanding of management practice.

FINALE of the U.N. International Year of Forests : culmination with a concert

Our Counselling and ISS team organised, in early December, 2011 a celebration of two years of art workshops and activities provided for our University post-graduate research students. The workshops had a number of benefits. They were to raise awareness of biodiversity and forests as well as providing a forum for engaging with others and an opportunity to belong to a semi-regular group. The 2010 theme had been the United Nations International Year of Biodiversity and the 2011 theme had been the United Nations International Year of Forests.

Teaching planning beyond the national context : pedagogic analyses of international fieldtrip experiences

Urban and regional planners, in the era of globalization, require being equipped with skill sets to better deal with complex and rapidly changing economic, socio-cultural, political and environmental fabrics of cities and their regions. In order to provide such skill sets, urban and regional planning curriculum of Queensland University of Technology (Brisbane, Australia) offers regional planning practice in the international context. This paper reports the findings of the pedagogic analyses from the regional planning practice fieldtrips to Malaysia, Korea, Turkey, Taiwan, and discusses the opportunities and constraints of exposure of students to regional planning practice beyond the national context.

The influence of justice theories on international climate policies and measures

While the justice implications of climate change are well understood by the international climate regime, solutions to meaningfully address climate injustice are still emerging. This article explores how a number of different theories of justice have influenced the development of international climate regime policies and measures. Such analysis is undertaken by examining the theories of remedial justice, environmental justice, energy justice, social justice and international justice. This article demonstrates how each of these theories has influenced the development of international climate policies or measures. No one theory of justice has the ability to respond to the multifaceted justice implications that arise as a result of climate change. It is argued that a variety of lenses of justice are useful when examining issues of injustice in the climate context. It is believed that articulating the justice implications of climate change by reference to theories of justice assists in clarifying the key issues giving rise to injustice. This article finds that while there has been some progress by the regime in recognising the injustices associated with climate change, such recognition is piecemeal and the implementation of many of the policies and measures discussed within this article needs to be either scaled up, or extended into more far-reaching policies and measures to overcome climate justice concerns. Overall it is suggested that climate justice concerns need to be clearly enunciated within key adaptation instruments so as to provide a legal and legitimate basis upon which to leverage action.